EGR has partnered with 4H Agency to bring its readers a series of long-form articles on the requirements and key facts and figures for a host of emerging markets throughout the world.
Tapping into 4H’s talent pool of experts, the articles will outline the regulatory framework and entry requirements for interested parties, as well as an insider’s view on how the market could shape up in the coming years.
Here, the series continues with Belgium, with commentary from 4H partner and head of consulting department, Ivan Kurochkin.
Market overview
Belgium, a Western European country with a population of approximately 11.8 million and a GDP of around $644.8bn in 2023, ranks 22nd on the 2024 Corruption Perceptions Index – positioned between the UK and the UAE. It operates as a federal state with a mature legal system and well established regulatory institutions.
In 2023, Belgium’s gross gambling revenue (GGR) was estimated at approximately US$2.4bn. This reflects a market that is significant in scale but tightly regulated.
Gambling in Belgium is governed by a strict regulatory framework aimed at balancing consumer protection with limited market access. The foundation was laid by the Belgian Gaming Act 1999, which introduced licensing and oversight for land-based gambling. In 2011, online gambling was formally legalised – now, it is only permitted for operators already holding a land-based licence.
Belgium applies a channeling policy, which prioritises controlled access over prohibition. The aim is to direct players to a small number of licensed, secure operators, both online and offline. The National Lottery remains under state control, while all other gambling activities are subject to strict licensing conditions.
Regulations
Belgium regulates all general gambling verticals which are semi-open for the licence issuance (except for online and land-based lottery, which are covered by the state monopoly). There are the following types of licences and permitted games:
- Online gambling:
- Online casino licence (Class A+)
- Online slots licence (Class B+)
- Online sports betting and racing licence (Class F1+)
- Land-based casino licence (Class A). Permitted games include table games and slot machines games
- Slot machines:
- Slot machines in casinos (Class A; therefore, the land-based casino licence)
- Slot machines in arcades (Class B)
- Slot machines in drinking establishments (Class C)
- Sports betting:
- Sports betting licence (Class F1)
- Sports betting establishment licence (Class F2) – for gambling establishments that accept bets on behalf of the F1 sports betting licensee
- Racing licence (Class F1P)
- B2B licence (Class E)
There are several general requirements applicable for all licence types, including that application for a licence must include required corporate and personal documents. Other requirements differ and are applicable for each particular licence, as detailed below.
Online gambling requirements
- Only holders of land-based licences (Class A, B and F1) can apply for relevant online licence (Class A+, B+ and F1+ accordingly).
- Online gambling servers must be located in a permanent establishment within the Belgian territory.
- Additional documents shall be submitted in case a land-based licensee is applying for online gambling licence
Land-based casinos requirements
- Land-based casino licences are limited to nine, although all of them have already been granted. Therefore, the regulator is not issuing new land-based casino licences (and online casino licences accordingly)
Slot machines requirements
- Land-based slot machines located in land-based casinos do not require an additional licence (Class A)
- Land-based slot machines located in arcades (Class B) are limited to 180 licences
- Land-based slot machines located in drinking establishments (Class C) are not limited in number of licences. However, Class C slot machines licensees can install a maximum of two bingo machines and a maximum of two machines with reduced stakes
- Slot machines must pay out a minimum of 84%
Sports betting requirements
- Land-based sports betting (Class F1) licences are limited to 30.
- Land-based sports betting establishments (Class F2) licences are not limited. Only sports betting shops, bookmakers, newsagents and racing associations can apply for a sports betting establishments (Class F2) licence.
- Sports betting shops’ applicants shall present the following additional documents for the licence issuance:
- Proof to the regulator that there are no others existing betting shops within 1,000 metres of their location,
- Covenant concluded between the operator of the betting shop and the municipality where the establishment is located,
- Opinion from the local mayor stating that the legal operating conditions are met and respected.
Racing requirements
- Horse racing betting (Class F1P) licences can be issued only to the holders of sports betting licences (Class F1).
- For horse racing betting only the following bets are permitted:
- Mutual bets on horse races that take place in Belgium, and which are organised by a racing association approved by the competent federation
- Pari-mutuel betting on horse races that take place abroad
- Fixed or conventional odds betting on horse races taking place in Belgium and organised by a racing association that’s approved by the competent federation
- Fixed or conventional odds betting on horse races that take place abroad.
B2B providers requirements
- B2B licences (Class E) are issued for the sale, rental, import, export, manufacture, maintenance and repair of gambling equipment.
- B2B licensees cannot also hold, whether directly or indirectly, any other gambling licence (either online or land-based).
Licence cost and term
Online gambling
- The term of each online gambling licence is tied with the term of the relevant land-based licence.
- Applicants must pay a “guarantee” (deposit fee) before they can obtain one of the following licence types:
- Online casino (Class A+): ~$280,000.
- Online slots (Class B+): ~$84,000.
- Online sports betting (Class F1+): ~$84,000.
- Operators must also pay an annual licensing fee:
- Online casino (Class A+) fee: ~$12,300.
- Online slots (Class B+) fee: ~$12,300.
- Online sports betting (Class F1+) fee: ~$14,100.
Land-based casino
- The term of land-based casino licence is 15 years with a possibility of renewal.
- Applicants must pay a “guarantee” (deposit fee) before they can obtain land-based casino licence in amount of ~$280,000.
- Operators must also pay an annual licensing fee in amount of ~$24,700.
Slot machines
- The term of a land-based slot machines licence differs depending on the type of licence, namely:
- Term for slot machines located in land-based casinos (Class A) is tied with a term of the relevant land-based casino licence
- Term for slot machines located in arcades (Class B) is nine years.
- Term for slot machines located in drinking establishments (Class C) is five years.
- Applicants must pay a “guarantee” (deposit fee) before they can obtain one of the following licences:
- Slot machines located in land-based casino (Class A): same amount as a guarantee for land-based casino.
- Slot machines located in arcades (Class B): ~$84,000.
- Slot machines located in drinking establishments (Class C): are exempt from a guarantee fee.
- Operators must also pay an annual licensing fee:
- Slot machines located in land-based casino (Class A): same amount as a license fee for land-based casino.
- Slot machines located in arcades (Class B): ~$12,300.
- Slot machines located in drinking establishments (Class C): ~$841.
Sports betting
- The term of a land-based sports betting licence differs depending on the type of licence, namely:
- Term for land-based sports betting licence (Class F1): nine years,
- Term for land-based sports betting establishment licence (Class F2): three years.
- Applicants must pay a “guarantee” (deposit fee) before they can obtain one of the following licence types:
- Land-based sports betting (Class F1): ~$11,200,
- Land-based sports betting establishments (Class F2): are exempt from a guarantee fee.
- Operators must also pay an annual licensing fee:
- Land-based sports betting (Class F1): ~$14,100.
- Land-based sports betting shops (Class F2): ~$4,300.
- Other land-based sports betting establishments (bookmakers, newsagents, and racing associations, Class F2): ~$2,000.
Racing
- The term of a racing licence is tied with applicable sports betting licence (Class F1).
- Applicants for a racing licence are exempt from “guarantee” (deposit fee).
- Operators must also pay an annual licensing fee in amount of ~$14,00
B2B
- The term of a B2B licence (Class E) is 10 years with a possibility of renewal.
- Applicants must pay a “guarantee” (deposit fee) before they can obtain one of the following licences:
- B2B applicants that provide exclusive maintenance, repair or equipment services for gambling: ~$28,000,
- Other applicants: ~$4,100 per tranche of 50 gaming machines.
Taxation
In Belgium, the gambling tax structure is set at a regional level.
Additionally, there are also some general taxes, applicable to all companies established under Belgian laws:
- 25% tax on corporate income
- 12% VAT tax
- 30% withholding tax
Responsible gambling & AML
In Belgium, gambling is subject to a strict regulatory framework focused on both responsible gambling and anti-money laundering (AML) compliance. Operators are required to implement a wide range of player protection and risk mitigation measures to maintain a controlled and transparent gambling environment. These include:
- Age restriction – access to both land-based and online gambling is limited to individuals aged 21 and over.
- Self-exclusion mechanisms – online operators must offer players the option to self-exclude temporarily. During the self-exclusion period:
- Operators must refrain from all promotional communications to the excluded individual.
- Exclusion requests can be submitted by the player or by third parties.
- All exclusions are registered in a central electronic system that applies to casinos, slot arcades and betting shops.
- The minimum duration of a self-exclusion period is three months.
- Loss limits in land-based venues – maximum average hourly losses are imposed depending on the type of establishment, for example for slot machines in:
- Arcades: ~$28 per hour.
- Drinking establishments: ~$14 per hour
- Deposit limits for online gambling amount to a maximum of ~$1,340 per week. Players may request a higher limit.
- Online operators must use notifications and pop-up messages to inform players about gambling risks and encourage responsible play.
- Customer due diligence (CDD) – operators must carry out CDD, especially for transactions of ~$2,200 or more (individually or in aggregate), and/or transactions involving high-risk factors or unusual patterns.
Additionally, enhanced due diligence (EDD) must be applied in the following high-risk situations:
- Customers from countries classified as high-risk.
- Politically exposed persons, including their family members and close associates.
- Customers from jurisdictions with low or no taxation.
- Customers subject to international sanctions or asset freezes.
- In such cases, internal management approval is required to establish a business relationship.
- Each player must be assessed individually based on their profile, transaction patterns and payment methods. Operators must ensure their controls align with broader national risk assessments. All procedures must be proportionate to the level of money laundering or terrorism financing risk.
- Before transactions can be executed, operators must verify that the payment method used belongs legally to the player.
Marketing
Gambling advertising in Belgium is subject to strict regulation. In 2023, a broad ban on nearly all forms of advertising came into force, followed by further restrictions on where and how gambling can be promoted. These rules tightly control both the placement and content of marketing to limit exposure, particularly among vulnerable groups.
There are following main regulations concerning gambling advertising in Belgium:
- All gambling advertisements must include the message “Gamble responsibly!”. The font must be at least 4% of the ad height, minimum size of seven points and not smaller than 25% of the largest font used in the ad.
- Advertising of gambling is banned across the following media: TV and radio, websites and social media platforms, newspapers and printed materials, public posters, personalised messages via email, SMS, messaging apps and social networks.
- Ads on the building facade of gambling premises must not exceed 30% of the total facade area and 20 sq m in size, including window ads within 10 cm of the glass. If multiple gambling operators are located in one building, the permitted area is calculated per establishment.
- Advertising must not target minors or persons under 21 years of age, feature individuals who are or appear to be underage, appear in media or places primarily aimed at minors, use visuals or characters popular among minors, encourage underage individuals to persuade others to gamble, or target socially vulnerable groups.
- Online gambling licensees must have a clear and restrained advertising policy to be able to advertise on its website, and a designated contact person must be available to the regulator and authorised to stop any marketing campaign upon request.
- Ads must not offer free participation, bonuses, stake reimbursements, or promise new stakes, exaggerate chances of winning, suggest gambling is a solution to financial or personal problems, etc.
Market specifics for entry
As of the date of this article, Belgium maintains a limited and tightly controlled gambling licensing system. The number of licences issued across various categories is strictly capped and, in most cases, all available licences have already been granted. The following licences are currently in circulation:
- Online casino (Class A+) – Nine.
- Online slots (Class B+) – 49.
- Online sports betting (Class F1+) – 22.
- Land-based casino (Class A) – Nine.
- Land-based slot machines in arcades (Class B) – 175.
- Land-based slot machines in drinking establishments (Class C) – 4,170.
- Land-based sports betting (Class F1) – 30.
- Land-based sports betting shops (Class F2) – 409.
- Land-based sports betting bookmakers (Class F2) – 26.
- Land-based sports betting newsagents (Class F2) – 1,315.
- Land-based sports betting racing associations (Class F2) – Five
- B2B (Class E) – 169.
At present, no new online gambling licences (Class A+, B+, F1+) are available. This is largely due to the fact that online licences in Belgium are not issued independently; they are linked to corresponding land-based licences, which are themselves capped and fully allocated.
For example, the number of land-based casino licences is legally limited to nine. All nine have been issued, meaning no additional applications for land-based or online casino licences are possible. Similarly, no new licences are being granted for slot machine arcades (Class B), which effectively blocks access to an online slot machine license (Class B+) as well.
The situation is similar in the sports betting sector. Land-based sports betting (Class F1), as well as most related betting shop and bookmakers licenses (Class F2), are currently unavailable. The only accessible F2 subcategories are for newsagents and racing associations.
B2B licences (Class E) remain open for issuance and are not subject to numerical limits.
In addition, Belgium requires a separate operational licence (Class D) for staff working in casinos, arcades, or betting shops. This licence can be obtained upon presenting an identity card and completing mandatory training, indicating a relatively low barrier for individual workers compared to operators.
The 4H view
Belgium’s regulatory framework is well organised and prioritises oversight, though such a licensing regime is notably restrictive, with a combination of three core factors:
- strict limitation on the number of licences,
- current unavailability of most key licenses
- highly regulated procedures for both obtaining and maintaining them
This positions Belgium as a conservative jurisdiction rather than a liberal one in terms of market access.
Such an approach raises questions about long-term sustainability and market competitiveness. While stringent controls may serve consumer protection goals, they can also hinder innovation, discourage new market entrants and entrench existing players.
As the online gambling sector evolves and digital entertainment continues to expand, Belgium may eventually need to reconsider its licensing model. A more open, transparent and scalable system could offer greater flexibility for both operators and regulators, while still upholding high standards of integrity and player protection.
Ivan Kurochkin is one of the founders of 4H Agency, partner and head of the Eastern Europe desk at 4H.
After 10+ years’ experience in consulting every type of clients from the testing laboratories to global operators and B2B providers on a variety of matters related to the gambling operations, Ivan has proven himself to be a business-oriented multi-jurisdictional advisor for entering new markets across the globe.
Ivan’s background helps him to choose the best and most efficient scenarios for expansion to new market or for bringing existing operations of 4H’s clients to a significantly new level. Ivan is also an expert in the field of responsible gambling and frequent author for industry media.
The post The 4H View: Everything you need to know about Belgium first appeared on EGR Intel.
EGR has partnered with 4H Agency to deliver a monthly insight into regulated markets’ key requirements. This month, Belgium is in the spotlight
The post The 4H View: Everything you need to know about Belgium first appeared on EGR Intel.